Changing Industry. UST Population (Ohio) Number of Tanks. Year 60,000 50,000 40,000 30,000 20,000 10,000

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2 Number of Tanks Changing Industry 60,000 UST Population (Ohio) 50,000 40,000 30,000 20,000 10,000 0 Year Source: Ohio Petroleum Underground Storage Tank Release Compensation Board (2010) 2

3 Changing Industry 92% 47% 43% Facilities Owners Facilities per Owner UST per Owner 1 3, % 3, % 8, % % % 1, % % % 1, % % % 1, % % % % % 1, % 3, % % % 1, % % % 1, % % % % > % % 1, % 3,692 7,830 22,615 Source: Ohio Petroleum Underground Storage Tank Release Compensation Board (2010) 3

4 Industry Challenges New and alternative fuels Reformulated Ultra Low Sulfur Diesel (ULSD) Bio-Based Ethanol Blends Bio-Diesel Equipment compatibility Fuel quality Changes in UST regulations Energy Act requirements USEPA review of 40 CFR 280 4

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6 ULSD - Background Who What U.S. California Refiners & Importers Downstream from Refineries through Fuel Terminals Retail Outlets Import/produce at least 80% ULSD for on highway use Import/produce at least 100% ULSD for on highway use Facilities that choose to carry ULSD must meet 15 ppm sulfur specification 6/1/2006 6/1/2010 6/1/2006 9/1/2006 All highway diesel must be ULSD 10/1/2010 7/15/2006 Facilities that choose to carry ULSD must meet 15 ppm sulfur specification 10/15/2006 All highway diesel must be ULSD 12/1/2010 9/1/ % of highway diesel fuel dispensed as of the first quarter 2010 is ULSD (USEPA ULSD pump survey) 6

7 ULSD - Background Reduced sulfur Additives to inhibit biological growth Additives to increase lubricity Some bio-diesel blending Additives to inhibit corrosion 7

8 ULSD - Issues Issues began surfacing in late 2008 Raised to national spotlight in December 2009 Petroleum Equipment Institute chaired a meeting of stakeholders in January 2010 Focus on corrosion Conduct survey The stakeholders group met again in April 2010 Review initial survey results 8

9 ULSD - Survey responses 496 (42%) with issues 696 (58%) without issues 10.5 locations/respondent Distribution of locations with issues 1 49 (11%) 2 45 (10%) 3 65 (14%) (23%) (22%) 6 50 (11%) 7 58 (12%) 8 54 (12%) 9 30 (6%) (10%) Canada - 10 (2%) 464 of 496 responding 449 of 496 with comments 9

10 ULSD - Issues ATG Probes Accelerated Corrosion? In tanks (including vehicle yanks), tank equipment, including drop tubes, line leak detection sensors and flow meters Submerged Pump Plugged filters Clogged solenoid valves Equipment malfunctions Other Issues? Deteriorated gaskets and seals Nozzle malfunctions (failure to turn off) Shear and check valve malfunctions Seal/gasket/O-ring deterioration Dispenser leaks/failure/premature replacement Inside Saddle Tank 10

11 ULSD - Issues Study conducted by the Naval Research Laboratory in 2009 Overall, B100 had the highest propensity for biofouling while the highest corrosion rates were measured in ULSD exposures. Source: Microbiological and Corrosivity Characterizations of Biodiesels and Advanced Diesel Fuels, Jason S. Lee, Richard I. Ray*, Brenda J. Little, Naval Research Laboratory,

12 ULSD - Causes Theories of what is causing the problem Water intrusion in the tank system Promotes microbial activity Microbes Interaction with corrosion inhibitor additives Creates a diesel soap that can consume the inhibitors Formation of acidic acid Fuel quality/additive Electrical problems (bad grounds) 12

13 Industry Impacts Dispensing system integrity Replacement of dispensing system components Releases to the environment Slow dispensing rates Fuel quality Contamination control Poor fuel-performance in vehicles and equipment (inefficient combustion, dark exhaust smoke) Impact to vehicle and equipment fuel filters and fuel system components 13

14 ULSD - Conclusion Something is up 58% did not experience a problem related to USLD BUT 42% reported some type of problem they believed was related to ULSD AND The issue does not appear to be limited to UST 14

15 ULSD - Conclusion The issues appear to be more than accelerated corrosion The issues need to be better defined The cause and solution needs to be identified Some amount of research is needed Who s to blame? Does it really matter right now? 15

16 ULSD - Further Investigation More detailed survey of sites indicating corrosion Detailed review of existing data Gather additional data Understand issues that may be associated with the storage and dispensing of ULSD Clarify the relationship between ULSD and corrosion 16

17 ULSD - In The Meantime Implement a tank and product quality management program Be diligent in water management monitor tanks on a routine basis remove water when found when water is found check for microbes 17

18 ULSD - In The Meantime Implement a tank and product quality management program (continued) Take early symptoms seriously slow-flow issues, clogged filters, indications of equipment corrosion Evaluate bottom sample and take appropriate actions. Have the tank properly cleaned if a significant rag layer is present Periodic treatment with biocide where problem may be persistent 18

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20 Biodiesel Biodiesel is a vegetable oil- or animal fat-based diesel fuel meant to be used in standard diesel engines. Can be used alone (B-100), or blended with a petroleum-based diesel (B-5, B- 20). 20

21 Bio Diesel Issues Water solubility/phase separation The water-fuel interface can be corrosive and promote microbial growth B100 can release varnishes and gums from tank and piping walls Petroleum Bio Diesel Ethanol Blends Dissolved Water 100 1,250 2,500 4,000 40,000 Free Water Yes Yes No Metal Corrosion Below water line Primarily below water line Overall system corrosion Source: Brief Overview to Fuels and Materials Compatibility Presentation at 2007 National Tanks Conference by Edward W. English II, Fuels Quality Services 21

22 Ethanol Blended Fuel IFC 2009 Chapter 22 Alcohol blended fuels, including those containing 85-per cent ethanol and 15-per cent unleaded gasoline (E85), are flammable liquids consisting of ethanol or other alcohols blended greater than 15 per cent by volume (). Proposed NFPA 30A TIA Alcohol Blended Motor Fuel. Motor fuel consisting of a blend of alcohol, such as ethanol, and gasoline, with an alcohol concentration greater than 10 percent by volume, including those with nominally 85 percent ethanol /15 percent unleaded gasoline (E85). 22

23 Ethanol Blended Fuel Issues Water solubility/phase separation Water saturated blends can be corrosive Petroleum Bio Diesel Ethanol Blends Dissolved Water 100 1,250 2,500 4,000 40,000 Free Water Yes Yes No Metal Corrosion Below water line Primarily below water line Overall system corrosion Source: Brief Overview to Fuels and Materials Compatibility Presentation at 2007 National Tanks Conference by Edward W. English II, Fuels Quality Services Fuel conductivity Ethanol has a greater conductivity than petroleum fuels 23

24 Ethanol Blended Fuel Issues Solvent action Can loosen rust and other materials from walls of tanks and piping and suspend sediment Equipment compatibility metal components due to conductivity non-metal components due to solvent interaction Swelling Discoloration Softening Delaminating Embrittling 24

25 Ethanol Blended Fuel Issues E-15 Waiver Indications are that EPA will approve E-15 EPA has pushed a decision to later this year Issues that need to be considered Use in older vehicles Dispenser labeling Dispensing system Compatibility Listing requirements 25

26 Ethanol Blended Fuel Issues NFPA attempted to implement a tentative interim amendment (TIA) to address E-15 equipment issues Dispenser testing for mid-level ethanol blends The National Renewable Energy Laboratory (NREL) is testing E15 (15% ethanol, 85% gasoline) compatibility with regular gasoline dispenser systems Publication of results is expected in the third quarter of this year 26

27 Ethanol Blended Fuel Issues Fire codes Motor fuel dispensing system components to be listed for the material dispensed Approval to change to ethanol blends (IFC 2009) UST regulations Compatible with the material stored 27

28 Ethanol Blended Fuel Issues There are three fuel dispenser certification (listing) paths for new equipment: UL Standard 87 for gasoline and ethanolgasoline blends up to E10 UL Subject 87A-E25 for gasoline and midlevel ethanol-gasoline blends up to E25 UL Subject 87A-E85 for gasoline and ethanol-gasoline fuel blends up to E85 28

29 Ethanol Blended Fuel Issues UL certified E25 dispensers (UL Subject 87A-E25) Dresser Wayne Ovation Eco Fuel Gilbarco Encore Flex Fuel S No hanging hardware is certified for E25, which includes hoses, swivels, nozzles, and breakaways. Warranty for E15 Dispenser Gilbarco announced they will honor warranty for dispensers manufactured after April 1, 2008 that dispense E15 29

30 Ethanol Blended Fuel Issues E85-certified equipment Dispensers Gilbarco Encore Series 300, 500, 550 Dresser Wayne G520, G610, G620, Ovation Model E Hose: Veyance Flexsteel Futura Ethan-all Nozzle: OPW 21GE and 21GE-A Swivel: OPW 241TPS-0492 Breakaway: OPW 66V-0492 Shear valves: OPW 10P-0152E85 and 10P- 4152E85 Submersible turbine pump: FE Petro all AG models 30

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32 Energy Act requirements Secondary containment New installations Upgrade requirements Under dispenser containment Operator training Turnover Recordkeeping 32

33 USEPA review of 40 CFR 280 Release prevention Overfill functionality testing, walk through checks, spill bucket testing and integrity testing for interstitial areas Release detection walk through checks and periodic operational checks and periodic testing Address alternative fuels and compatibility 33

34 USEPA review of 40 CFR 280 Fully regulate emergency generator USTs Regulate Airport hydrant systems with alternate release detection requirements Field-constructed USTs with alternate release detection requirements Regulate wastewater treatment tanks 34